| Case ID |
2b3ca70c-c9ec-4901-b799-d1aaf55ab184 |
| Body |
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| Case Number |
I.T.T.A. No. 64 of 2000 |
| Decision Date |
Jun 17, 2014 |
| Hearing Date |
|
| Decision |
The court answered the questions of law raised by the appellant in favor of the appellant regarding the inclusion of amounts reflected in books of account as undisclosed income in block assessment proceedings. The court held that only adverse material unearthed during the search could form the basis for block assessment, not amounts already disclosed in earlier years. However, the court ruled against the appellant concerning the deductibility of certain undisclosed expenditures that were not satisfactorily explained. Therefore, the appeal was partly allowed. |
| Summary |
The case revolves around the appeal filed by Srinivasa Ferro Alloys Ltd. against the order of the Income Tax Appellate Tribunal regarding block assessments under the Income Tax Act. The primary contention was whether amounts already disclosed in regular income tax returns could be classified as undisclosed income during a block assessment. The court ruled that such amounts could not be treated as undisclosed income, emphasizing that only evidence uncovered during a search could justify such classification. The case also addressed the deductibility of certain expenditures not recorded in the books, which the court ultimately ruled against the appellant. This case highlights critical aspects of tax law, particularly concerning block assessments and the treatment of undisclosed income, making it significant for tax practitioners and businesses navigating tax compliance. |
| Court |
High Court
|
| Entities Involved |
Not available
|
| Judges |
L. Narasimha Reddy,
Challa Kodanda Ram
|
| Lawyers |
Y. Ratnakar,
S.R. Ashok
|
| Petitioners |
Srinivasa Ferro Alloys Ltd.
|
| Respondents |
Assistant Commissioner of Income Tax, Central Circle, Visakhapatnam
|
| Citations |
2014 SLD 1944,
(2014) 368 ITR 424
|
| Other Citations |
CIT v. Vinod Danchand Ghodawant [2001] 247 ITR 448/114 Taxman 90,
CIT v. B. Satyanarayana [2013] 356 ITR 323/220 Taxman 86/[2013] 38 taxmann.com 174
|
| Laws Involved |
Income Tax Act
|
| Sections |
260A,
132,
158BC,
253(1)(B),
69C,
158B
|